ML19312D766
| ML19312D766 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 03/17/1980 |
| From: | Clemenson F, Knight J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19312D762 | List: |
| References | |
| NUDOCS 8003250309 | |
| Download: ML19312D766 (80) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
PORTLAND GENERAL ELECTRIC Docket No. 50-344 COMPANY, E &.
)
(Control Building)
(Trojan Nuclear Plant)
NRr STAFF TESTIMONY OF FRED CLEMENSON AND JAMES E. KNIGHT REGARDING MODIFICATION WORK AND EFFECTS ON PLANT OPERATION AND ON SAFETY-RELATED EQUIPMENT (CFSP Contentions 12, 13, 15, 16, 17; and Board Questions)
Q.1 Please state your name and position with the NRC.
A.1 My name is Fred Clemenson.
I am a Senior Systems Analyst, Plant Systdms Branch, Division of Operating Reactors, U.S. Nuclear Regulatory Commission, Washington, DC 20555.
A.1 My name is James E. Knight., I am a Senior Electrical Engineer in the Systematic Evaluation Program Branch, Division of Operating Reactors, U.S. Nuclear Regulatory Commission, Washington, DC 20555.
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80032 50 k[
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,s. Q.2 Have you prepared a statement of professional qualifications?
A.2 Yes. A copy of our statements is attached to this testimony, Q.3 Please state the nature of the responsibility that you have with respect to the proposed modification work at the Trojan Plant.
A.3 We are assigned to review the proposed Control Building modifica-tions filed by PGE on January 17, 1979 to determine the effects of the proposed nodification on plant operation and on safety-related equipment.
A.4 What is the purpose of your testimony?
A.4 The purpose of our testimony is to respond to the following contentions and Board questions and concerns relative to the effects of the proposed modifications on plant operation and on safety-related equipment:
Contentions CFSP'12 and 13 The facility cannot be operated safely while the modification work is being performed and there has been no demonstration that operation during modifica-tion work will not pose an undue risk-to the public health and safety.
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.. CFSP 15 Licensee has not identified all safety equipment or equipment needed for safe operation of the plant that would be affected by the proposed modifications.
CFSP 16 Licensee has not made adequate plans to protect all safety equipment and equipment for safe operation during the modification work.
CFSP 17 Perfomance of modification work will hamper the ability of plant operators to respond to any emergency properly and thus poses an undue risk to the public' health and safety.
Board Questions and Concerns Testimony should be presented giving considerable detail on the steel embed-ment to be installed to facilitate installation of the steel plate and on the sequence of installation.
(Tr. 3172).
As to installation of the steel plate:
(a) How is the plate movement limited i,y be vertical columns if the plate should be dropped?
(Tr. 3172).
l
1
.. (b) Describe the equipment that will be used to hold the harnesses (2) that will be on the steel plate.
(Tr. 317E).
(c)
(Board Question 14)
A complete and detailed installation procedure should be provided for all of the steel plates.
(Tr. 3534 and 3172)
(d) Particular attention should be paid to the plate at elevation 93' where the plate is being placed over areas in which cables are present.
The sequence of work as well as provisions for protect-ing cables should be described in detail and it should be demon-strated that there are measures to assure that the sequence will be followed and that protection for cables and equipment will be adequate.
(Tr. 3172-73).
(e) Sketches should be presented showing the area where plates will be placed and the procedure for getting them there and installing them.
(Tr. 3173-74).
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,. (f)
(BoardQuestion19)
Identify all safety-related equipment including cables at any point where there is any potential impact of construction proce-dures and techniques.
(Tr.3534)
Q.5.
Briefly summarize the Control Modifications proposed by PGE?
A.5.
The Control Building modifications consist of the addition of three new reinforced concrete shear walls across the existing railroad bay in the Control Building.
Part of the new west wall would extend south of column line 46 into the existing locker room at elevation 45'.
In addition, part of the west wall would be further strengthened by the addition of a three-inch thick steel plate bolted to the outside of the wall between elevations 59'-3" and 97'-3" with high-strength steel bolts.
To facilitate handling, fabrication and erection, the steel plate will be installed sequentially in a total of eight pieces and welded together.
The steel plate has four cut-outs for the pas-sage of electrical cables and associated cable trays.
The steel plate pieces have been designed so that, when assembled, the openings are fonned around the cables, making it unnecessary to remove them for plate installation.
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.. The new east wall would extend above the railroad bay to elevation 95'-6" and be fastened to the existing east wall with reinforcing steel and high-strength steel bolts.
The existing equipment access opening in the east wall at eleva-tion 65' would be reduced in size to 4 feet square.
The existing diesel generator combustion air path consists of the open railroad bay of the Control Building.
Because this path would be closed off by the new walls, PGE would install a new diesel generator combustion air intake in the north wall of the Turbine Building located to the west of the Control Building west wall. To provide another possible unrestricted path, a roll-up door would be relocated to the west of the louvered diesel air intake.
The railroad spur, which presently runs through both the Turbine and Control Buildings to the Fuel Building, would be terminated in the Turbine Building. A railroad bumping post would be placed at the end of the line.
A second railroad spur would be added to maintain railway service to the Fuel Building.
.. 0.6 Have you evaluated the proposed modification work to detemine how damage to safety-related equipment could possibly occur or safe operation could be affected from perfomance of this work during operation?
A.6 Yes.
Q.7 Based on this evaluation would you identify the areas of concern resulting from the performance of this proposed work?
A.7 Modification work which raises concerns as to potential effects on equipment and safe operation and the areas of concern are:
1.
drilling holes through walls, 2.
bolt assembly installation, 3.
welding and cutting operations, 4.
modifications to safety systems required for performance of the Control Building modifications, 5.
effects on operator actions, 6.
steel plate installation, 7.
_ construction generated dust and dirt, and 8.
noise and vibration due to modification work.
In addition, there are concerns with regard to work sequence, and structural effects of the modification work which will be addressed by other Staff witnesses.
a 8-Other than these areas, there are no aspects of the proposed modifications that will have an impact on safety-related equipment or the safety of plant operation.
Q.8 Why is it necessary to drill holes into the Control Building?
A.8 Holes will be drilled into the Control Building walls to provide for bolting steel plates to the west wall of the Control Building as well as to provide for bolting the new wall at column line N to the existing structure.
It will be necessary to drill holes through the west and east walls between colurrn lines 41 and 47 and in the Electrical Auxiliaries Room to insert reinforcing steel for the attachment of the new wall at column line N'.
Q.9 How could this work affect safe operation of the facility?
A.9 Such drilling could potentially affect safety-related cables, cable trays, equipment and/or conduit at the following locations:
l 1.
the west wall of the Control Building / east wall of the Turbine Building between elevations 77' and 93' where four banks of cable trays and conduits pass through the walls from the Control Building to the Turbine Building.
. 2.
the west wall of the Electrical Auxiliaries Room, between elevations 65' and 77' where safety-related cables in trays and conduits are located near the inside of the wall, 3.
the west wall of the Cable Spreading Room between elevations 77' and 93' where safety-related cables in trays and conduits are located near the inside of the wall, 4
the Control Room west wall between elevations 93' and 97'3" where several safety-related conduits are located near the inside of the wall, 5.
the east wall of the Control Room between elevations 93' and 95'6" between column lines 41 and 46 (no safety-related equip-ment or cables are at this location),
6.
the east wall of the Cable Spreading Room between elevations 77' and 93' between column lines 41 and 46 where safety-related cable trays are located near the wall, 7.-
the east wall of the Electrical Auxiliaries Room between elevations 65' and 77' (no cable trays near the wall, one electrical cabinet near the wall), and i
8.
the floor of the Electrical Auxiliaries Room at column N' (no safety-related equipment or cables are located at these drilling sites).
Q.10 What methods and procedures will be used to protect components or equipment in the Control Building or in Control building walls from damage during performance of the drilling of the holes in the Control Building that you have identified?
A.10 For each of these areas, the licensee will determine the location of each hole to be drilled by surveying.
The survey methods to be used provide a precise location of the holes by means of tape measurements from existing column lines and by means of a survey transit where it is necessary to establish additional points of reference.
This method should allow the location of holes with sufficient accuracy to prevent damage to all but the imbedded conduits discussed separately below.
Once the location of'the hole is established on the side of the wall from which drilling is to be done, the location of the hole on the opposite side of that wall will be accurately established using the same survey methods described above and marked prior to the commencement of drilling. The holes must be located where there are no obstructions and where there is sufficient space between the wall and any cables, cable trays or conduit near the l
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.. wall to allow installation of the washer and the nut on the bolt.
This requires a horizontal distance from the wall to the nearest cable, cable tray or conduit at the hole location to be at least five inches to accommodate the large washer (approximately 2-3/8 inches thick), a small washer (approximately 1/4 inch thick), the nut (approximately 1-3/4 inches thick), about 1 inch of grout, plus excess bolt length beyond the tightned nut. A radial dis-tance from the hole of at least nine inches is required to accom-modate the washer against the wall. Consequently, prior to drill-ing a particular hole, the surveying operations will be performed to assure that the hole location is such as to allow at least these minimum distances between the wall hole and the nearest cable or conduit where the drill bit comes through the wall.
Therefore, for any hole, the drill would have to penetrate through the wall and then continue to travel at least an additional five inches before any contact with cables, conduits, cable trays or equipment could occur.
j A positive drill control will be provided. This will prevent con-tact with cable trays, cables, conduits or equipment by limiting the extent to which the drill can travel past the surface of the wall once the drill has penetrated the wall.
The drill advance thrcogh the wall is controlled manually; that is, a rack and pinion gear must be rotated by hand before the drill can advance.
- e. 1 This provides for a slow positive control over the drill prevent-ing any punch-through once the wall is penetrated and thereby preventing any damage to cable trays, conduits or equipment on the opposite side of the wall.
For each hole to be drilled, a painted stripe or tape will be provided on the drill so the operator knows what depth has been penetrated and thereby be aware when the drill has penetrated the wall depth.
In addition, personnel will be stationed at the opposite side of the wall from the driller to monitor the hole location and drill penetration.
Positive communications between the monitor and driller will be provided by means of portable radio communications or by sound or battery powered telephones to assure that the drilling is terminated as soon as the drill penetrates the wall.
For the areas described it. A.9 item 1, drilling will be parallel to the four banks of cable trays and conduits which pass through the walls from the Control Building to the Turbine Building.
' Sufficient space must be provided between the location of holes to be drilled and the existing cable trays / conduit which pass through the walls to accommodate the drilling equipment as well as the width of the washer (9 inch radius) _and nut which will ultimately be installed on the bolt. This space is sufficient to assure that drilling in this area will not result in contact between the drill
.o and the cable trays / conduit which pass through the wall.
For the areas described in' A.9 items 2 through 4, 6 and 7 above, cables, cable trays and conduits are located only on the side of the wall opposite the side from which drilling will take place.
For these areas, the five inch minimum required spacing between the surface of the wall and the nearest cable tray / conduit at the hole loca-tion, along with the positive drill control and the communications between the driller and personnel monitcring the drilling, will assure that the drill will not contact cable trays, cables or conduit.
For A.9 items 5 and 8, there are no safety-related equipment, cables or conduit on the opposite side of the wall and floor where drilling is to be accomplished.
0.11 Do you believe that the measures you have just described can be practically implemented?
A.11 Yes.
Q.12 Do you believe that the measures you have described will prevent any damage to safety-related cables, cable trays and conduits from drilling?
A.12 Yes. However, we believe there is one exception to the above-described method for accurately predetermining hole location to I-
. prevent damage to conduits containing safety-related cables.
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Q.13 What is that exception?
A.13 At the west wall of the Control Building near column line 46 on column line R there are two conduits, each containing two cables, that are embedded in the concrete.
Q.14 How can the location of these two conduits be determined?
A.14 The location of these conduits can be determined approximately by finding where the conduits enter and leave the wall; then, marking their approxirate location by drawing straight lines between these points.
Q.15 Does this assure that you would not contact one of these conduits?
A.15 No, however, once the approximate location of the conduits is determined, contacting them during drilling would be unlikely since the area of the embedded conduits can be avoided during drilling.
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i Q.3' Would the conduit protect the cables if the conduits were con-l tacted during drilling operations?
l A.16-Firstly, the drill operator should recognize the difference in the behavior of the' drill motor when the core drill contacts the 1
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.. conduit and withdraw the core drill.
Second, the conduits are constructed from rigid steel which would provide some protection for the cables that they contain.
Q.17 What would happen if the drill operator contacted a conduit, did not recognize the difference, continued to drill through the conduit, and damaged the cables in the conduit?
A.17 Depending on which conduit was impacted, some of the nuclear instrumentation would be lost. However, redundant instrumentation from three other channels would be available.
In the unlikely event that cables from both conduits were damaged, an inadvertent scram could occur.
Safe shutdown of the plant would be unaffected since the plant is designed to handle such occurrences and redun-dant instrumentation for neif tr:a monitoring would be available.
Q.18 What methods and procedures will be used to protect cables, compo-nents or equipment in the Control Building from damage during installation of the Bolt Assembly?
A.18 First, the bolt assemblies which consist of bolts, washers and nuts will be installed at each drilling location that we identi-
'ied in our answer to Q. 9.
The concern is that safety-related cables in open cable trays are present in certain of these areas l
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.. and could be damaged if tools or the large steel washers were inadvertently dropped onto the cables.
To avoid damage to the cables, the licensee has committed to install solid steel cable tray covers to prevent damage to cables from the dropping of tools, nuts or washers.
In addition, a supervisor will be in attendance during these operations to assure that the cable tray covers are in-place and that care is taken in the installation of the bolts, nuts and washers.
Q.19 Phat assurance do you have that these measures are adequate to protect the cables during installation of the bolt assemblies?
A.19 An analysis of the drop of one of these large steel washers, using the conservative assumption that the corner of the washer strikes the cable tray cover and that the impact energy is concentrated in i
the corner was performed by the Licensee which demonstrates that the cable tray cover will not be punctured for washer drops from slightly greater than 3 feet above a tray.
In addition, the licensee has proposed to construct scaffolding with timber plank-ing against the R line wall at each location where a plate washer will be installed.
Coverage of the planking will be such that the maximum height a washer could drop to the scaffold planking is
- 3. feet.
A test will be performed by dropping one of the large steel washers onto the planking.
If the planking cannot withstand the drop, an additional layer of planking will be added.
During
..- installation of the plate washer, the washers will not be lif ted over the trays unless the planking is in place.
The planking covera'ge will be such that in the event a washer drops onto a steel tray the drop height will be no more than 3 feet.
Q.20 Could the proposed modification work affect fire protection at the Trojan facility?
A.20 Yes. The proposed modification work could potentially affect fire protection at the facility because of (1) the possible intro-duction of ignition' sources from the modification work; (2) the possible accumulation of combustible materials from the mcdifica-tion work; (3) the potential impaiment of fire brigade access to areas of the facility due to storage of construction equipment and/or materials, work-in-progress or other aspects of the modi-fications; and (4) impairment of fire barriers.
Q.21 Identify the ignition sources and areas containing combustible materials that could be affected by such ignition sources.
A.21.
Ignition sources that will be introduced by the modifications are Cadwelding, electrical arc welding and cutting by electric arc or oxyacetylene torch.
Such sources raise a possible concern with regard to the potential for. ignition of combustible materials.
.. Areas where Cadwelding, welding or cutting will be perfomed which may contain combustible materials such as electrical cable insula-tion, wood and plastics are in the Turbine Building above eleva-tion 69' along the R line wall (division A cables here), and the Electrical Auxiliaries Room at elevations 65' to 77' near column 41 R.
Such work may also be required in the Cable Spreading Room and the Control Room.
Q.22 What measures will be taken to assure that fire protection at the Trojan facility will not be compromised during the proposed modi-fication work?
A.22 Administrative controls required under the facility's NRC approved fire protection plan provide that it is the joint responsibility of the Cognizant Supervisor, the Safety Supervisor and the Shift Supervisor to review and evaluate proposed work activities to identify potential transient fire loads and other potential sources of danger.
Prior to the initiation of any Cadwelding, welding or cutting work in the plant, a welding or cutting pennit must be obtained by the responsible supervisor. This permit requires, i
l among other things, that combustible materials in the area where welding or cutting is to take place be removed or that potentially combustible materials such as the insulation on installed elec-t-
f-trical cables be protected from welding and cutting operations.
The pennit also requires that a trained fire watch (one or more
- n. plant personnel trained in fire-fighting) equipped with a fire extinguisher or hose be present in the work area.
The fire watch must remain.in the area for 30 minutes af ter completion of the welding or cutting to assure that no fire or smoldering has occurred.
With regard to physical fire protection for the cables, the licensee has committed to using Claremont Weld Shield 800-24 or Fabricote 1584-white fire blankets over all cables in the area where welding and/or cutting will be done.
These are designed to stop welding and cutting slag and sparks from penetrating the blanket and reaching items protected by the blankets.
Q.23 In your opinion do these blankets offer the protection that they were designed for?
A.23 Yes.
Q.24 What is th basis for your opinion?
A.24 Our evaluation of the qualification test procedure and the test results and report for these blanket materials.
-Q.25 Are there any additional measures that will be taken to assure that fire protection at the Trojan facility will not be com-promised during the proposed modification work?
.o A.25 Yes.
In addition, the licensee has committed to remove wood form materials prior to commencement of any welding or cutting opera-tions and to store other necessary flammable material such as rags in self-closing containers which will be removed from the area at the end of each work day.
0.26 In your opinion will the measures you have described above provide adequate protection in preventing fires or detecting and extin-guishing fires in areas where welding, cadwelding and cutting operations are being performed.
A.26 Yes.
Q.27 Ider,tify the possible accumulation of combustible materials from the modification work?
A.27 Smoke will be generated by welding, Cadwelding and cutting opera-tions as will some dust from concrete removal. To protect the equipment in the Electrical Auxiliaries Room from the work at column 41 R, an enclosure of fire retardant plastic and wood will be constructed around the work area with fans provided to direct any smoke and dust outside.
If such work is necessary in the Control Room or Cable Spreading Room, a similar enclosure will be provided there as well.
Plastic and wood used to con.=truct enclosures will remain for the duration of work in an area.
Other i
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.. plastic sheeting will be removed from any safety-related area at the end of the work shif t.
In addition, wood will be used for foms for concrete pours 1 ' some areas and such wood forms will remain in place until concre.e pours are completed.
Because the modifications require construction equipment, mate-rials and tools to be brought into the areas where modification work is to be perfomed, this will result in the temporary intro-duction and use, while work is actually being performed, of minor combustibles such as wood, rags, rubber tires on dollies, and the like.
Q.28 Will introduction of these combustibles result in the accumulation of combustibles and increase the potential for fires in safety related areas.
A.28 Aside from wood used for concrete foms and wood and pisstic used for dust enclosures, the modifications will not lead to the accumu-lation of combustibles and an increase in the potential for fires in safety-related areas because:
1.
Plant procedures require safety-rdated areas to be free of-permanent material storage at all times and equipment, mate-rials, tools and combustibles will not be stored near safety-l related equipment, components, cables or piping either during l
work periods or non-work periods.
1
.. 2.
While equipment, matet !als and tools for construction may be brought into safety-related areas during work periods, they are required to be removed at the end of each work shif t; consequently, safety-related areas will not be used for storage of combustible materials or equipment for any unattended period of time.
Q.29 Identify the areas where wood for concrete fonns and wood and plastic for dust enclosures will be used.
A.29 The licensee has identified the following safety-related areas where wood will be used:
1.
Control Room; 2.
Cable Sr tading Roon; 3.
Electrical Auxiliaries Roem; 4
East wall of the Turbine Building between column lines 41 and 46.
Q.30 What measures will be taken to assure that these con ustibles will not increase the potential for fires in the identified areas?
A.30 The plastic and wood will be fire retardant with the exception of the wood used as concrete form material. This will not be treated with fire retardant chemicals to avoid any possible deleterious
.. effects the chemicals may have on the new concrete.
Inasmuch as these materials represent a significant increase in the quantity of cor.bustible material for the period while the material is in the area, the licensee has committed to establish a fire watch whose sole responsibility will be to tour at hourly intervals the areas where these materials are used.
This fire watch will be established whether the wood and plastic are fire retardant or not. This fire watch will not be necessary during the times when a continuous watch has been established in an area for other purposes.
This fire watch will be instituted when the material enters an area and continue until it is removed.
Q.31 Do you believe that these measures will assure adequate protection for these areas where wood and plastic may, of necessity, have to remain during offwerk periods?
A.31 Yes.
Q.32 Are there any other concerns with regard to the potential of the i
modification work to affect fire protection?
i A.32
'Yes, it is possible that work could block access by the fire l
brigade. Access by the fire-brigade could be inhibited by:
.. 1.
the storage of construction equipment, materials or tools blocking ingress and egress to and from areas of the Control Building complex, 2.
workers and actual work-in-progress blocking ingress and egress to and from areas of the Control Building complex, 3.
the removal of access ways (e.g., stairwells, ladders) for performance of modification work.
Q.33 In your opinion will the matters you have identified in response to Q.32, above, inhibit operator or fire brigade access?
A.33 No.
Q.34 What is the basis for your answer.
A.34 As previously indicated, construction equipment, materials and tools will not be stored near safety-related equipment or cables.
Consequently, access to such areas will be unaffected from the standpoint of storage of construction items. While construction equipment, materials and tools may be present temporarily in safety-related areas during any particular work shif t, such items must necessarily be of portable nature (since they must be removed
,e.
at the end of each work shift) and will be atored so they do not block access required for operation or for firefighting.
As to workers and actual work-in-progress blocking access to any areas in the Control Building complex, it is to be noted that all modification work will be closely supervised; in the event that workers are blocking access, they can simply be directed to move.
Also, work in the Cable Spreading Room, the Electrical Auxiliary Rooms and the Control Room will not restrict access to equipment either within these areas or in adjacent areas because the loca-tion of the work is against the walls out of normal paths to equipment and the tools and equipment to be used to perform modi-fication work in these areas is small in size (e.g., wrenches, nuts, washers).
In the case of the work at column N' in the Electrical Auxiliaries Room, the work will consist of cutting sore concrete at floor level and therefore will not block acc'ess to any safety-related equipment.
The plastic enclosures to be constructed in the Electrical Auxiliaries Room and which may also be constructed in the Control Room and Cable Spreading Room to prevent dust and smoke from entering these areas will be against walls and hence will not impede access to any safety-related equipment.
Furthermore, during a site visit in June 1979 we examined all areas of the Control Building Complex for possible operator / fire brigade access problems.
l
.. Based on that examination and a consideration of the modification work to be performed, the only area where work-in-progress will affect access is at elevation 45 feet in the Turbine Building between columns 41 and 47.
In this area, access through this area from the. railroad bay to the Control Building will be impaired temporarily while plates 1 through 6 are lifted into place.
This impaiment of access will last only for the period of time in which the plates will be lifted from elevation 45 feet to their point of installation. This will not restrict access to any safety-related area where access is necessary either to operate equipment or to fight fires because safety-related equipment is not located in the areas to which access would be impaired.
In addition, other access ways into these areas are available.
These alternate routes provide access from the outside or the inside around the work area which is temporarily inhibited while the plates are being lifted into place.
Consequently, the modification work-in-progress will have essen-tially no effect on operator or fire brigade access.
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Q.35 Will the removal of access ways during the perfomance of the modification work impair access by operators or the fire brigade?
A.35 To perform certain parts of the modification work, the steel stairway leading from the Turbine Building operating floor at
- elevation 93 feet to the Control Room viewing gallery will be removed. This stairway provides access only to the viewing gallery and is not an access way to any safety-related equipment, components, piping or esbles since no safety-related items are in A
the viewing gallery area. An alternative access way is available into the viewing area should access be required to fight a fire in this area.
In view of this, the impairment of access to the viewing gallery by temporary removal of the stairway will have no safety significance with regard to ingress and egress to and from the area by operators or the fire brigade.
Also, pursuant to the modification work, a ladder and steel plat-form leading to the crane cab at elevation 93' in the Turbine Building will be temporarily removed. However, eccess to the crane cab is not necessary for safety-related purposes and there-fore a determination of such access is not required.
Q.36 Are there any other concerns related to fire protection?
A.36 Yes, the possible impairment of fire barriers because of the modification work.
- 0.37 Where and how might this occur?
I '
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.. A.37 Based on our review of all aspects of the proposed modification work, areas where work may affect a fire barrier are the areas where holes will be drilled through existing walls as identified in our response' to 0.9 above, the floor in the Electrical Auxil-iaries Room at column line N' where holes will be drilled for anchoring a new wall, at column 41 R and possibly at 46 R, 46 N and 41 N at various elevations where concrete removal for rebar installation will result in penetration of the wall.
Penetrations resulting from the drilling and concrete removal operations on these walls will provide a path through which fire could poten-tially pass.
Q.38 What measures will be taken to assure that fire protection will not be compromised due to the effect of the proposed modification work on the fire barrier?
A.38 The Trojan technical specifications require a fire watch patrol to inspect, on an hourly basis, the areas where a fire barrier is nonfunctional. The licensee has committed to providing an hourly fire watch whenever wood is in any of these areas and the fire watch will also be required whenever walls have been penetrated and adequate fire protection measures such as approved fire stop sealant are not installed.
In addition, where holes have been drilled for. bolt ins, 11ation, the licensee has committed to temporarily seal the holes, until the bolts are installed, with
... the same material used to seal the plant's electrical penetrations of fire barriers.
This is in compliance with Trojan Technical Specification 3/4 7.9, " Penetration Fire Barriers," which covers
.the requirements for periods when a fire barrier is impaired or is nonfunctional.
Q.39 In your opinion will the measures you described in A 38 provide adequate protection to compensate for the disabling of fire barriers?
A.39 Yes.
Q.40 What is your conclusion with regard to the effects of the modi-fication work on fire protection at Trojan?
A.40 The measures, previously described with regard to (1) the possi-ble introductior,of ignition sources from the modification work; (2) the possible accumulation of combustible materials from the modification work; (3) the potential impairment of fire brigade access to areas of the facility due to storage of construction equipment and/or materials, work-in-progress or other aspects of the modifications; and (4) impainnent of fire barriers provide reasonable assurance that the health and safety of the public will l
not be affected by the proposed modifications insofar as fire protection at the facility is concerned.
l I
A
.. 0.41 Will any safety-related equipment be taken out of service as a result of the modification work?
l A.41 We have examined the proposed modifications with a view tow rd 3
determining the need for intentionally taking equipment out of service during performance of part or all of the modification 3
work. We initially determined that the only safety-related equip-ment which might be temporarily taken out of service was the Battery Room exhaust.
However, the licensee has since stated that the Battery Room exhaust duct will not be disabled during the modification. We have reviewed and determined that the exhaust duct need not be disabled to accomplish any modification work.
Therefore, there will not be any safety-related equipment taken out of service as a result of the modification work.
Q.42 Is there any concern that the proposed modification work could affect operator actions?
A.42 Yes.
The potential concern with regard to modification work affecting operator actions is the possibility that the storage of construction equipment, materials and tools, actual work-in-progress, or the removal of accessways during the modification work could impair the access of operators to safety-related equipment and thus impair or prevent manual operator actions necessary for normal
- operation or to cope with' emergencies.
There is also a concern that construction generated noise could interfere with operations in the Control Room. We have addressed these concerns in A.50 and 51.
1 Q.43 In your opinion will the proposed modification work affect oper-ator action in a way that could impair the access of operators to safety-related equipment and thus impair or prevent manual operator actions necessary for normal operation or to cope with emergcncies.
A.43 No.
Q.44 What is the basis for your ansv.ar.
A.44 As we indicated in our testimony on fire protection, construction equipment, materials and tools will not be stored near safety-related equipment or cables or in safety-related areas. Conse-quently, operator access to such areas will be unaffected from the i
standpoint of storage of construction items.
Similarly, excopt for work involving movement of plates at eleva-tion 45 feet in the Turbine Building, work-in-progress will not impair operator access since workers and the tools and materials they are using will simply be moved out of the way if access is required. Moreover, areas at elevation 45 feet in the Turbine l
l
~.
.. Building where access will be impaired while plates are moved are not safety-related areas containing any equipment for which access is necessary and, in any event, alternate accessways exist.
Finally, while the modification work will require the temporary removal of both a stairway leading from the Turbine Building operating floor (elevation 93 feet) to the Control Room viewing gallery and a ladder and platfonn leading to the crane cab no safety-related items requiring operator access are contained in these areas.
Accordingly, temporary removal of these access ways will not impair operator access to any equipment, cables, piping or components which are necessary for plant operation or which serve a safety-related function. Here, too, alternate accessways are available.
Q.45 Identify the proposed modifications that could be the potential source of noise and vibration.
A.45 1.
Numerous holes will be dril' led in the west wall of the Con-trol Building between columns 41 and 46 from elevations 59'-3" to 97'-3" for the installation of the steel plates.
There will also be through-wall holes drilled in the east wall of the Control Buidling between columns 41 and 47 from elevations 65'-0" to 95'-6" for structurally connecting the new wall to the existing wall. The new east and west Control I
3
.. Building walls enclosing the railroad bay between columns 41 and 47 and elevations 45'-0 and 65'-0" will be structurally attached to the existing walls using reinforced steel grouted into holes drilled into the existing structure. The Control Building along column N' will be strengthened by the addition of a new reinforced concrete wall and footing in the railroad bay.
Its elevation will be from below elevation 45'-0" to the underside of the floor at elevation 65'-0".
It too will be structurally connected to the existing walls and ceiling utilizing drilled holes and embeds.
2.
The concrete in the Control Building corner area at the junction of columns 41 and R line will be removed in order to expose, partially remove, and re-install additional rein-forcing steel in order to properly join the existing east-west wall along column 41 to the newly modified R line wall from elevation 65' -0" to 77'-0".
Concrete removal may similarly occur at columns 46R, 46N and 41N at various ele-vations.
3.
Removal of Control Building concrete blocks will be required.
For example, a new opening will be made in the block wall at column line 46 between column lines R and 0 at elevation 45'-0".
A portion of the Turbine Building floor slabs at 1
.. elevations 93'-0" and 69'-0" along column line S between columns 41 and 46 will be removed to provide clearance and eliminate interference with the new Control Building west wall. The floor slab and railroad spur foundation concrete will be removed along column line R between columns 41 and 46.
4.
A two-inch wide strip will be removed from the top and bottom flanges of the existing Turbine Building steel girder at elevation 93'-0" in order to obtain the required clearance between the new Control Building west wall and the east wall of the Turbine Building.
j l
i 5.
The relocated railroad spur shown in Figure 3.1-1 of PGE-1020 which is outside of the Control Building will involve the removal of approximately 350 cubic yards of rock.
Q.46 What commitments has the licensee made with regard to reduction of noise and vibration?
A.46 For the performance of all this work, the licensee'has comitted to the following:
a.
Explosives will not be used for the removal of structural material'or earthwork; l
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.. - b.
The tools employed to accomplish the work will have the minimum noise level consistent with the task; c.
The removal of the earthwork associated with the new railroad spur will usa hydraulic or air operated hammers, small front end loaders and dump trucks; d.
Removal of conventional back fill material around the build-ing will be accomplished using light hand tools such as shovels. Should rock be encountered, light power tools will be used.
Q.47 Do you believe that the vibration resulting from the performance of the modification work will affect the operation of equipment or components.
A.47 No.
Q.48_
What is the basis for your opinion?
A.48 The most severe vibration-producing work is that involving the use of ai or hydraulic operated hammers involved in the modifications as well as small front-end loaders for excavation and fill for the 7. - -
+
T
"?"*'T
..., - relocated railroad spur.
This excavation and fill will occur out-side existing buildings at grade level.
Similar excavation work has been performed at the site in the past and has not resulted in excessive vibration in the structures.
Also, hydraulic operated hammers and light power tools will be used for the removal of fill material around buildings and for the removal of concrete and block at columns 41R (and possibly at 46R, 46N and 41N). While all of this work as well as the drilling operations may create some low level of vibration, we believe that vibration resulting from perfors.ce of the modification work should have no effect on the eqiipment and components which must be qualified to withstand the severe vibratory motions from earth-quakes up to and including the SSE.
Q.49 What is the concern with regard to construction generated noise?
A.49 As to noise, the concern in this regard is that construction-generated noise will interfere with operations in the Control Room, either by drowning out the annunciators or by interfering with operators' voice ccmmunications.
Q.50 In your opinion will the construction-generated noise drown out
'the annunciat*,re or interfere with operators' voice communications?
c.
- '. A.50 No.
Q.51 What is the basis for your opinion?
A.51 As. can be seen from the work described above in A.45, with the exception of the drilling of holes in walls and the removal and replacement of concrete, construction will be carried out at an appreciable distance from the Control Room which is located at elevation 93'.
The distance from construction activities men-tioned above should serve to substantially reduce the level of noise reaching the Control Room from the site of the construction activities.
Moreover, the existing Control Room walls and floor slabs will serve further to muffle noise coming from construction activities.
Although drilling into the Control Room east and west walls will occur, the drilling operation will involve the use of diamond tipped core drills.
This will materially reduce both noise and vibration generated by drilling because of the large number of_ tool cutting edges which provide clean smooth cutting.
A water spay on the drill will also minimize noise and vibration.
In addition, the positive feed of the drill allows noise and vibration to be minimized through low speed feeding.
- Finally,
-drilling will take place from the outside surface of the Control Building walls. Consequently, the noise from drilling will be attenuated by the wall itself.
38 -
Moreover, the licensee has committed to maintain construction noise to levels so as not be interfere with normal voice communi-cation in the Control Room.
Should the Control Room operator determine that construction noise interferes with normal voice communications, lighter weight tools or other means of material removal will be employed to reduce noise. As a condition of the proposed. modifications, we recommend that the NRC Resident Inspec-tor be empowered to require the use of lighter weight tools or the employment of other means for material removal to reduce noise.
Since the sound level of Control Room annunciators is significantly above that of normal voice communication, the ability to hear annunciators is also assured.
A.52~
Please describe the necessity for installation of steel plates.
A.52 To upgrade the horizontal shear strength of the Control Building west wall adjacent to the Turbine Building, a three-inch thick steel plate will be attached to the outer surface of the west wall of the Control Building between column lines 41 and 47.
Q.53 Briefly describe the make-up of the steel plate as well as its installation and location of installation.
A.53 The plate will extend from elevation 59'-3" to 97'-3" between columns 41 and 47, a distance of approxinately 33'-6" at its i
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.. widest point.
It will be assembled from eight individual plates that will be lifted sequentially from a transporter in the Turbine Building railroad bay, and transported to their mounting positions with a combination of temporary and permanent plant devices.
After being properly positioned, the plates will be anchored to the existing wall by bolting. All mating edges of individual plates will be joined by welding to fonn one continuous plate.
The individual plates will range in weight from 2,700 pounds to 47,000 pounds. The roper plates (identified as plates 7 and-8) will be of such shape as to permit them to be lowered into posi-tion without disturbing the cables contained in four groups of cable trays passing between the Control Building Cable Spread Room (elevation 77') and the Turbine Building.
Q.54 Describe the sequence of installation for the first six plates?
A.54 Starting with the lowest plate, the first six plates (identified as plates 1-6), ranging in weight from 7,000 pounds to 24,000 pounds, will be sequentially lifted from the transporter using the 25 ton capacity hoist of the Turbine Building crane and placed on a dolly at grade level (elevation 45').
The dolly will move the plates to a point below where they will be lifted into position by the 16 ton capacity chain hoists mounted to the Turbine Building crane rail-support beam. Aside from the support provided the chain hoists by the Turbine Building crane rail support beam, the rigging will be such that each chain hoist, sling and attachment point on
the plate will be independent of the others.
For the first six plates, two chain hoists will carry the load. A third chain hoist, positioned over ecch plates's center of gravity, will be provided to serve as a backup in the event of a single failure of either of the two load carrying hoists.
Q.55 What assurance is there that the hoists will be able to carry the load of the plates.
A.55~
The safety margins of the load. carrying hoists for the first six plates, with respect to their static load rating, will range between 2.6 and 9.1.-
Assuming a failure in one of the two load carrying hoists, the safety margin for the backup hoist, with respect to its static load rating, will range from 1.3 to 4.5.
Furthermore, the static load rating of these chain hoists is 20 percent of their ultimate design load capability. Therefore, the safety margins, with respect to the ultimate load carrying capa-bility of the hoists, are five times the above.
Q.56 Do you believe that this margin of safety is adequate to assure that the hoists will not fail.
I L
l A.56 Yes, because it provides substantial capability for load carrying l-beyond the loads to be carried.
. 0.57 Identify the essential systems that are located below grade that could be affected by dropping plates 1 through 6?
A.57 The essential-systems that are located below grade and could be affected by dropping plates I through 6 are Train A and B fluid lines and electrical cables. With the exception of the Train B electrical conduit, the systems run below grade in the east-west direction parallel to the existing railroad tracks, and are located between columns 41 and 46. The fluid lines are the service water lines to both Emergency Diesel Generators, the service water suc-tion lines for both the turbine and diesel engine driven Auxiliary Feedwater Pumps and fuel oil supply lines for both A and B Emergency Diesel Generators. The centerline of the water lines is located 2'-0" below the railroad bay floor (elevation 45') and the fuel oil lines are 3'-6" below the railroad bay floor.
The concrete conduit containing Train A electrical cables supplies power to the Service Water, Component Cooling, Centrifugal Charging, RHR, Containment Spray, and Safety Injection Pumps. These cables range in depth below grade from 5'-9" to 8'-10".
The other concrete conduit contains Train B electrical cables supplying power and/or
-control for the following Train B systems:
Component Cooling and Service Water Valves, Engineered Safety Feature Initiation, Diesel Generator subsystems such as Fuel Oil Transfer Pump, Fuel Oil Valve, and Train B diesel air compressor. This conduit is located between columns 46 and 51 and also is in the area of the building
. modifications.
It is located directly below the southern end of the added Control Building west reinforced concrete wall.
The below-grade depth of the cables ranges from 4'-8-1/2" to 8'-6".
Q.58 Will any measures be taken to protect the essential equipment below grade should one of the plates (1-6) be dropped?
A.58 A temporary energy absorber will be provided at elevation 45'-0" directly beneath the west wall of the Control Building where the plates will be installed. This absorber will provide protection to essential equipment below grade at this location.
Q.59 Describe this energy absorber.
A.59 It will be conservatively sized to accommodate the maximum kinetic energy capable of being developed by a plate during the handling operations without exceeding the allowable compressive stresses on the underlying concrete and rock foundation.
It will consist of a crushable corrugated aluminum structure, two three-inch thick steel plates and an appropriate guide to ensure that the impact load will be distributed over the energy absorbing material.
Q.60 Will this energy absorber protect the below-grade conduits and piping for essential systems should one of the plates numbered 1 through 6 be dropped during the handling operations.
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1 A.60 Yes.
0.61 What is the basis of your answer?
A.61 From our evaluation of the proposed energy absorber, we have detennined that it has been conservatively designed so as to limit the impact loading such that damage to the pipes and conduits below grade will be precluded.
Q.62 Describe the sequence of installation for the remaining two plates indicating the precautions taken to preclude damage from a plate drop.
A.62 The last two plates, numbered 7 and 8, weigh 2,700 pounds and 47,000 pounds, respectively. After installation of plates 1 through 6, plates 7 and 8 are to be sequentially lowered into position above the four groups of cable trays which run between the Control and Turbine Buildings at elevations ranging from 77'-0" to 88'-3".
To accomplish this, they will be lifted from the transporter in the Turbine Building railroad bay (elevation 45 feet) with the 25 ton capacity Turbine Building Crane auxiliary hoist to the Turbine Building operating floor (elevation 93 feet) and then transported laterally over the Turbine Building operating floor to a location within the reach of the chain hoists. Three of the.16 ton chain hoists will be attached to plate 7 (2,700 1
.- pounds) and then it will be lowered into position.
Z bars mounted on the installed and anchored plates 5 and 6 will provide lateral guidance and restraint to plate 7 as.it is being lowered into position. To reduce the impact load on the previously installed plates in the very unlikely event that plate 7 should be dropped, a corrugated aluminum HEXCEL stabilized and pre-crushed energy abscrber will be mounted on plate 4 below.
Q.63 What assurance is there that the three hoists described above will be able to carry the load of plate 7.
A.63 In the handling of plate 7 by two of the 16 ton chain hoists the safety margin at rated static capacity will be 23.7.
In the event one of the two hoists should fail the backup hoist will have a rated static capacity safety margin of 11.8.
Since the rated capacity of the three hoists is 20% of the ultimate capacity, all the above ultimate factors of safety will be five times greater.
Q.64 Do you believe these safety measures are adequate to provide assurance that the hoists will not fail.
A.64 Yes.
Q.65 Describe the installation of Plate 8.
\\
. A.65 After being lifted to the Turbine Building coerating floor, plate 8 will be placed on and attached to a temporarily constructed plate support frame and roller. Two A-shaped frames will be attached to plate 8 (one on each side) prior to the time that it
'is transported across the Turbine Building operating floor. The purpose of these A-shaped frames is to' provide vertical stability and thereby prevent a flat plate drop of plate 8 onto the operating floor. To attain additional control over plate 8 during further movement, one end of the plate will be attached to one of the 16 ton chain hoists.
By means of light rigging equipment, the plate will be positioned below the Turbine Building crane rail and the row of 16 tone capacity chain hoists. Three additional hoists will then be attached to independent lifting points provided on the plate. Two of the four hoists will carry the load and the.
remaining two attached hoists will act as backup or redundant lifting devices in the event either of the two load carrying hoists should fail.
Q.66 What assurance is there that the hoists will be able to carry the load of plate 8?
L l
A.66 With respect to their rated static capacity, the safety margin for each of the two hoists supporting the load as well as each of the two backup chain hoists is 1.3.
With respect to the ultimate design capacity of the chain hoists, the static capacity safety margin is 6.5 for each of the lifting and backup hoists.
. Q.67 Do you believe this safety margin is adequate to assure that the hoists will not fail.
A.67 Yes.
1 Q.68 Describe the equipment that will be used that connects the hoists to the plates for both the 25 ton Turbine Building hoist and the 16 ton chain hoists, indicating the load carrying capability of f
this equipment.
.A.68 With respect to the use of the 25 ton Turbine Building hoist, the licensee has indicated two (2) leg bridle slings will be employed in the lifting and handling of all plates from the incoming transporter.
Each leg on both slings will consist of 1-1/4 inch diameter extra improved plow steel with an independent wire core rope and extra heavy thimbles spliced in with pressed sleeves. The breaking strength of this wire rope, at a minimum, is 147,030 pounds. The extra heavy thimbles will be used in making up the slings by splicing the thimbles in and then using pressed sleeves which conservatively will lower the efficiency of the slings to 80% of the wire ropes breaking strength, i.e., 117,624 pounds.
In the worst case, considering the sling angle of 69 degrees, the verti-cal load carrying capability is 109,811 pounds per leg of the sling or the ultimate load-carrying capability of the 2 leg bridle sling is 219,622 pounds.
Since the largest load is 47,000 pounds,
o.
. we calculate the least static safety factor to be 4.6.
Due to the more direct pull on the similarly constructural back up sling, we calculate its static safety factor to be 4.8.
Further, the out-board 2 leg bridle sling will have a turn buckle incorporated in it to permit its length to be adjusted such that the inboard slings will be attached to a weldless alloy master link having an ultimate load capability of 312,600 pounds.
Therefore for the heaviest plate, its static safety factor is 6.6.
Twenty-five ton shackles will be employed for making all attachments. Therefore, for the heaviest plate, the load on the shackles will be slightly more than one half of the rated capacity of the shackles.
With regard to the use of the three 16 ton chain hoists for handling plates numbered 1 through 7, single leg vertical slings will be utilized to place the plates in the proper vertical position.
Each of the three slings will consist of 1-1/4 inch diameter extra improved plow steel wire rope with an independent wire rope core.
Extra heavy thimbles will be ' spliced in with pressed sleeves. As previously discussed above, their ultimate static load-carrying capability is conservatively 117, 624 pounds. They will be essen-tially vertical. Therefore for the heaviest plate (24,000 pounds),
the ultimate static safety factor for the two load-carrying slings is 9.8.
Assuming one of the two load-carrying slings fail, the ultimate safety factor for the sling centered over the plate's center of gravity is 4.9.
- c 48 -
For plate 8_(weighing 47,000 pounds) four 16 ton chain hoists and associated single leg vertical slings will be utilized to place the plate in the proper vertical position.
The two outermost chain hoists and slings will carry the load while the two inner-mest hoists and slings will serve as back up in the event one of the two load-carrying hoists load paths should fail. Under the above assumptions, the ultimate static safety factor for the load-carrying slings as well a: the backup slings will be 5.
Q.69 Do you'believe that the equipment you have described in A.68 is adequate to safely handle plates I through 8 as proposed by the
' modification work?
A.69 Yes.
Q.70 What measures will be taken to provide protection in the event plate 8 is dropped?
A.70 To provide additional protection in the unlikely event that plate 8 should drop while being lowered into position, timber cribbing and stabilized, precrushed HEXCEL pads will be placed and supported by the top edges of plates 4, 6, and 7, prior to handling plate 8.
.The cribbing will be removed in 4 inch increments as the plate is lowered in a fashionEto assure that the maximum free drop height will not exceed 4 inches in the unlikely event plate 8 is dropped.
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7 p
.. Q.71' In your_ opinion will the cribbing and pads provide assurance that should plate 8 be dropped, the previously installed plates, bolts and associated structures could absorb the kinetic energy.
A.71 Yes..
Q.72 What is -the basis for this opinion?
A.72 The licensee has analyzed the dropping of plate 8 when it is being lowered into position to verify that the previously installed plates, bolts and associated structures could absorb the kinetic energy. The analysis shows that the dynamic load in the HEXCEL pad will not exceed 374,000 pounds. This was calculated using a conservative 1.3 factor increase of strength due to the dynamic load. A factor of '.1 while not_being as conservative as 1.3, would be more realistic.
A further conservatism in the licensee's analysis was the use of the factor 1.0 in determining the neces-sary HEXCEL pad thickness of 1 inch.
L Q.73 Is it your. testimony, then, that the proposed use of the HEXCEL pads alone would provide adequate protection to the installed plates, bolts and associated structures from a drop of plate 8.
l A.73 Yes.
l
... Q.74 What measures will be taken to assure that in the event that plate 8 is dropped it will be guided to avoid damage to the Con-trol and Turbine Building walls and cables which pass.from the Control Building to the Turbine Building between elevations 77' and 93'.
A.74 To assure that plate 8 is properly guided in the unlikely event of a load drop, three one-inch thick plates 2 feet wide and one one-inch thick plate of lesser width will be securely bolted to previously installed plates. The upper end of these one-inch thick plates will also be held in the proper position by the Turbine Building floor slab curb at elevation 93'-0".
Q.75 In your opinion will these measures protect the walls of the Control Building and Turbine Building as well as the cables which pass between the Control Building and the Turbine Building.
A.75 Yes.
Q.76-What is the basis of.your opinion.
A.~76 '
Prior to lowering plate-8, it will be suspended by the four 16-ton chain hoists directly over plates 5, 6 and 7.-
There are no known lateral forces being exerted on plate 8 at this time. Accordingly, if a drop did occur, it would be a straight vertical drop onto the timber cribbing and HEXCEL energy absorbers supported by plates 5, l
j
. 6 and 7.
Also the chain hoists attachment points.to plate 8 are
-so aligned that the three cutouts in the bottom edge of plate 8 will clear the three existing cable tray penetrations passing between the Control Building and the Turbine Building during the lowering of_ plate 8 or should there be a vertical drop of plate 8.
Q.77 With-respect to the handling of plate 8, will any other precautions be taken to assure that safe operation of*the facility is not compromised in the event that plate 8 did somehow sever the cables passing between the Control Buidling and the Turbine Building.
A.77 Yes, although the licensee has made the conservative assumption that all electrical cables in the upper three cable tray penetra-tions would be severed by a drop of plate 8 and concluded that.the plant could be brought to a cold shutdown condition with certain manual operations, to avoid the potential of unacceptable conse-quences due to any plant personnel's inability to-assess the status of the plant and take the required corrective actions, the licensee has agreed to place the plant in a cold shutdown condi-tion prior to the handling and installation of plate 8 and thereby obviate the need for the manual operation required to achieve a cold shutdown.
Q.78 Do you believe that the plant should be placed and held in a cold shutdown condition during the handling of plate 8.
.. A.78 We believe that the plant should be placed and held in a cold shutdown condition from the time plate 8 is lifted by the Turbine Building crane from the transporter at elevation 45 feet until plate 8 is secured to the Control Building west wall by all through bolts.
Q.79 What is the basis for this precaution.
A.79-Some uncontrolled motions may occur during the handling of plate 8 that could result in damage to the electrical cables in the upper three cable trays.
Placing the reactor in a cold shutdown mode would avoid reliance on substantial manual (and yet undefined) operator action that may be required as a result of damage to these cables-if the plant were not already in cold shutdown.
l Q.80 Would a drop of plate 8 which severed the cable trays you refer-
-enced in A.79 affect the ability to maintain a cold shutdown l
condition if the plant were already in cold shatdown?
A.80 No.
In the event that plate 8 were dropped, severing the three cable trays which pass between the Control and Turbine Buildings at approximately elevations 82 through 85 feet, only train "A" cables would be affected. The redundant train "B" equipment needed for cold shutdown would be unaffected since the train B cables needed for cold shutdown are not present in these cable I
1
'. trays..Therefore, the maintenance of a cold shutdown condition would be unaffected since only one train of this equipment is necessary to maintain cold shutdown.
Since the plant would have already been placed in the cold shutdown condition prior to the lowering of plate 8, the position of the valves for residual heat removal.would already have necessarily been established. The severing of the "A" cables would not result in the changing of the position of these valves. The power cables for the train "A" pumps necessary to maintain cold shutdown are buried in the ground below the concrete floor and would not be damaged.
These pumps could therefore be placed in operation by manual actuation of the breakers from the switchgear room.
Q.81 Could the handling of plate 8 cause damage to any other equipment?
~A.81 Yes.
Q.82 Describe the potential damages as well as the consequences of such damages.
' A.82 We have. reviewed the potential consequences in the unlikely event of uncontrolled movement of the 47,000 pound plate (plate 8) while it is being moved into position at the east end of the Turbine Building wall at elevation 93 feet. During this movement, the potential exists for the 47,000 pound plate to fall against and
. disable the two B train emergency. diesel generator exhaust sys-tems. The A train emergency diesel generator would be unaffected by this event because its exhaust systems are located near the opposite (west) Turbine Building wall.
In addition because the plant will be in cold shutdown condition prior to the plate 8 handling operations, damage to Train B diesel generator exhausts should have no affect on the ability to bring the plant to or maintain it in a cold shutdown condition provided, of course, that the Train A emergency diesel generator is operable. However, we believe that prior to handling plate 8, it should be verified that the Train A emergency diesel generator is functionally capable of responding to any demand for emergency power.
Q.83 Who will conduct the handling operations for the eight plates?
A.83-The load handling operations will be supervised and carried out by experienced and qualified Bechtel personnel plus journeymen skilled in their respective crafts.
Q.84
-What procedures will be taken with regard to load handling opera-tions to assure that these operations are conducted safely.
A.84 Prior to plate movements, procedures will be written, reviewed and approved by qualified Bechtel personnel. The craftsmen will be familiar with the equipment and procedures.
All hoists will be
. tested prior to commencing the lift operation.
Load cells will be incorporated in the load line of the backup or redundant chain hoists in order to reliably monitor the load lines to assure that they are taut but have not assumed an inordinate amount of the load.
Q.85 How is the plate movement limited by the veritical columns if the plate should be dropped?
A.85 Aside from the plate guides noted in A.74 and the Z bars noted in A.62 the only vertical structure that could limit lateral motions of the plates during their installation will be the west wall of the Control Building. However, as we noted in A.76 with respect to plate 8, lateral motions of the plates are not expected.
Once each of the eight plates are lifted and freely suspended by the 16 ton chain hoists plus associated slings (i.e., slings fabricated from 1-1/4 inch diameter extra improved plow steel wire rope with an independent wire rope core and extra heavy thimbles spliced in with pressed. sleeves) there are no known lateral forces exerted on the. plates. This is essentially so because the horizontal reach i
of the support brackets, attached to the Turbine Building crane rail support beam, places the chain hoist hooks directly over the vertical slot existing between the Turbine Building and the Control j
Building through which the plates must pass.
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. Q.86.
Based on the precautions you have indicated that will be taken by the licensee (including shutdown of the facility prior to handling plate 8) and the equipment that will be used to handle the eight plates, is it your opinion that safe operation as well as safe shutdown of-the Trojan facility can be maintained during the handling and installation of the eight steel plates?
A.86 Yes.
Q.87 Why is there a concern with the dust and dirt generated by the modifications?
A.87 The control, monitoring and powering of essential systems (essen-tial systems for the purpose of this review includes those systems-needed to bring the plant to cold shutdown conditions and maintain it'in a cold shutdown condition and those systems required to mitigate the consequences of accidents) is largely accomplished by electrical means which in_ turn require electrical contacts. When dust, dirt and/or grit is deposited on electrical contacts, the likelihood of making an acceptable electrical contact is very significantly reduced. Since the Control Building modifications involve the removal and replacement of concrete, building blocks and dirt as well as the drilling of many holes in the concrete, these operations have the potential of creating significant amounts.
of these airborne particulates.
.- Q.88 Identify the areas housing essential systems or the essential systems themselves that potentially could be impaired by construc-tion dust and' dirt?
A,88 The areas housing essential systems or the essential systems themselves that potentially could be impaired by construction dust and dirt are:
(a) Diesel Generator Systems, located in the Turbine Building at elevation 45 feet.
(b) Electrical Auxiliary Room, located in the Control Building at elevations 61 and 65 feet.
(c) Engineered Safety Feature Switchgear Room, located in the Turbine Building at elevation 69 feet, and (d) Control Room located in the Control' B'111 ding at elevation 93 feet.
Q.89 How can the modification work adversely affect the on-site emer-gency diesel generators?
A.89
. Modification work generated dust and dirt could potentially-affect the quality and quantity of ventilating and combustion air avail-able during and following the building modifications.
. Q.90 What measures will be taken to assure that there is an adequate supply of air to the emergency diesel generators?
A.90 Currently, _the air intake system for the emergency diesel genera-tors relies on an opening to the outside through the railroad bay in the Control Building.
Before the Control Building railroad bay is sealed off at column line R (Control Building west wall), an alternate air intake system will be provided in the north wall of the Turbine Building railroad bay. Therefore, an adequate supply of ventilating and combustion air will be available throughout the modifications.
Q.91 Has consideration been given to the potential blockage of this alternate air intake system?
A.91 Yes.
The new Turbine Building air 'ntake louver has been sized (182 square feet) to allow the blockage of 50 percent of the intake area by snow, ice or debris. The Turbine Building air intake louver has not been and need not be, designed to withstand abnonnal loads, since collapse of the louver would not preclude a sufficient air supply to the diesel generators.
If the Turbine Building railroad bay air intake were to be damaged or were to become clogged, sufficient air could be temporarily drawn from the Turbine Building ventilation system through the Turbine Building
.quipment hatch at-least until the louver is repaired or the i
i
1
. obstruction is removed from the louver or the Turbine Building railroad bay door is opened.
The total air requirements of both A and B train Emergency Diesel Generators would constitute approxi-mately 10 percent of the Turbine Building's air flow rate.
Further, should debris pass through the Turbine Building air intake louver, the larger pieces of debris would tend to settle out, because of the lower velocity of _the air in the Turbine Building railroad bay, before the air is drawn into the individual diesel generator compartment air intake systems.
Q.92 What measures will be taken to control the creation of dt t and dirt during the modification work?
A.92 The creation of dust and dirt will be controlled during the build-ing modifications by the use of water sprays and the perfomance of regular cleanups. Should it prove necessary, evacuation fans and ducts will be provided in the respective work areas. Upon completion of the work, normal housekeeping will preclude the presence of residual dust. All construction work will be sus-pended during-the periodic diesel generatur tests and following all automatic starts of the units.
Further, it should be noted that all electrical relays for the engines, located within-the diesel. generator compartments, are housed within dust-tight enclosures.
. Q.93 In your opinion, then, will the construction generated dust and dirt adversely affect the diesel generators' electrical relays and contacts or the ability of the diesel generators to operate safely during and following the proposed modification work.
A.93 No.
Q.94 In your opinion will the proposed modification work adversely affect the air supply for the diesel generators during or follow-ing the modification work?
A.94 No.
Q.95 Describe how construction-generated dust and dirt can affect the safety equipment in the Electrical Auxiliary Room, specifically identifying the safety equipment that could be affected.
A.95 The Electrical Auxiliaries Room is located in the Control Building between elevations 61'-0" and 77' -0" and columns 41 and 51. This
-room which is normally closed and locked, contains safety and non-safety related equipment.
The licensee has provided preliminary details illustrating the concrete modifications to be carried out on the floor and walls.
The following Control Building modifica-tions have been identified as potential sources of adverse condi-tions such as dust, dirt, debris and water that have the potential
. for degrading the safety-related equipment housed within the Electrical Auxiliaries room.
(a) At the junction of column lines R and 41, all concrete in the corner will be removed, between elevations 65'-0" and 77'-0",
in order to join the additional rebars of the strengthened R line wall to the existing rebars by Cadwelding.
(b) A series of 2 inch deep. slots (approximately 2'-0" long) and holes will be cut in the floor along column line N' from columns 41 and 46 for anchoring the rebar to the top of the N' wall at elevation 65'.
(c) A number of holes will be drilled in the R and N line walls in order to tie the added walls to the existing structure.
The following safety-related equipment has been identified as being within the area of influence of the column 41R modifications.
(1) 120 volt preferred instrument AC panels
ll and Y13 (2) Plant Static Inverters - Y15 and Y17 (3) Solatron Line Voltage Regulatory - Q35 and Q37 (4) Battery Charger - D21 (5) Train A Cable Tray ABA 288 - contains cables associated with the following train A safety related equipment:
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. a - Power for Inverter - Y15 b - Power for Battery Charger - D21 c - Power for Inverter - Y17 d - Power for Battery Charger - 023 e - Control for CCW and Service Water Valves -CV 3715A, SV 3303, SV 3287, and SV 3725 f - Control for Pressurizer Relief Valves PCV 455A, PCV 469 and CV 8021 g - Control for RCS Valves h - Control for Safety Injection Valves 1 - Main Steam Line Valves, SIS Test Line Valve j - Control for Diesel Generator A - G101 k - Control for AFW and CVCS valves M0 3071 and CF 8149, A, B, C 1
- Control Turbine Trip - Train A m - Control for ES 480V LC - B01/B03 n - Control for ES 4 KV switchgear Al o - Control for CVCS valves CV 8149 A, B. C p - Control for Reactor Trip Breakers q - Power for NIS cab A Control C 31A-r - Power for NIS cab A Instr. C31A s - Power for Process Protection Set - IC36Al t - Power for Process Control Group I C36A6 u.- Power for Diesel Generator - G101 v - Power for Radiation Monitoring Panel - C41A i
. w - Power for SS Protection Input Rack - C46A x - Power for SS Protection Input Rack - C47A y - Power for Containment Pressure Instrumentation z - Power for ESF DBA timers, AFW Pump Auto Start Circuit aa - Power for C.R. Vent Indication - C254 ab - Power for Safety Injection Status Lamps C29A ac - Power for Steam Generator Blowdown Sample Valves -
SV 2809A, 11A, 80A, 14A A.96 What measures will be taken to assure that construction generated dirt and dust resulting from the work at the junction of column line R and 41 described in A.95 will not adversely affect any safety related equipment?
A.96 Removal of concrete in the wall corner at 41 R will commence with cutting 1/2" deep vertical grooves at the boundary of the material to be removed. A 60 pound jack hammer, a chipping hammer, and wire brush will be utilized in breaking up and removing concrete and exposing the existing rebar. The existing rebar will be cut and joined by Cadwelding, to the new rebar.
Prior to commencing this modification the work area will be isolated from the equip-
-ment in the Electrial Auxiliaries room by erecting a dust-tight
-flame retardant enclosure from the floor (elevation 65'-0") to the ceiling (i.e., underside of the Cable Spreading Room floor-elevation 77'-0").
l Q.97 Do you believe that these measures are adequate to assure th6t the safety equipment in the Electrical Auxiliaries Room will not be degraded?
A.97 Yes, we believe that the proposed measures to keep dust, dirt, debris and water within acceptable limits are acceptable provided the work is periodically monitored and continued work is contin-gent upon approval by the NRC Resident Inspector.
Q.98 Are there any other concerns you have regarding the effects of this modification work on the Electrical Auxiliaries Room?
A.98 As a result of our review of this modification work, we believe that the licensee has failed to demonstrate that the proposed measures will adequately protect the above safety-related systems from missiles.
The safety-related equipment described in A.95 may be damaged by missiles generated by the modification activities or by missiles generated by other outside conditions because the current missile barriers (existing wall) will be removed, thereby exposing the equipment.
Q.99 What measures do you believe should be taken to protect this equipment from missiles?
. A.99 We believe that the plant should be placed and held in the cold shutdown condition throughout all phases of the modification work where essential equipment is vulnerable to damage from natural as well as building modification work-generated missiles.
In the alternative, plant shutdown would not be necessary if suitable protection of equipment from missiles, for example through the use of missile shields, were provided.
Q.100 Are the design details of the Electrical Auxiliaries room modifi-cations finalized?
A.100 No.
Q.101 What additional details of the modification work may be proposed?
A.101 It is possible, as the details are finalized, that work similar to that described at. column 41R may be required at columns 46R, 46N and 41N at various elevations.
Q.102 Will the' measures described by your answer above with respect to the modification work at 41R, be followed with respect to modifi-cation work at other locations?
.A.102_
In the event similar work is required at these other locations, the_ licensee should provide the same protective measures as those described for 41R.
' Q.103 What measures will be taken with respect to the modification work along column line N' from columns 41 to 46?
A.103 A diamond tipped concrete saw and a hand held chipping hammer will be utilized in making the series of 2" deep slots in the Electrical Auxiliaries room floor along column line N' between columns 41 to 46.
Further, a diamond tipped core drill will be used to drill two holes, in the bottom of each slot, through the remaining concrete opping and the precast floor panels for the placement of the U shaped rebar to be used to anchor the top of the N' wall to th3 floor slab. Water will be sprayed on the diamond tipped cutting tools.
It acts as a lubricant and a cooling medium and also prevents the dust from becoming airborne. A small hand held chipping hammer will remove the material between the saw cuts.
The dust, dirt, debris and excess water will be continuously cleaned up using mops, brooms, dust pans and a shop vacuum.
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Q.104 Do you believe these measures are adequate?
A.104 We conclude the described measures for work done at 41R and column line N', if properly implemented, will adequately assure that this modification work will not adversely affect the safety-related equipment in the vicinity of the work from the standpoint of dust l
and dirt generation.
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. However, to provide assurance that the adverse affects of the modification work activities are held to acceptable limits (e.g.,
dust, dirt and debris), the resident NRC inspector will periodi-cally monitor the work.
If in his judgment the measures taken to protect the essential equipment are inadequate, the work shall be stopped until adequate measures have been implemented. We also believe that such measures should also be implemented if similar work is required at 46R, 46N and 41N.
Q.105 Describe the modification work with respect to the anchoring of the three-inch thick steel plates to the Control Building R line wall as well as the measures that will be taken to suppress genera-tion of dust and dirt.
A.105 Anchoring of the three-inch thick steel plates to the Control Building R line wall will require that holes be drilled into the west wall of the Electrical Auxiliaries room.
Further, anchoring a new wall at column line N will require drilling into the east wall of tne Electrical Auxiliary Room portion of the Control Building between columns 41 and 46.
For the drilling of these holes, a positive feed control drill will be utilized. To sup-press the generation of airborne dust, water will be directed on the drill. To limit the accumulation of construction dust and dirt, regular cleanups will be performed.
~ The licensee has indicated (1) diamond tipped core drills and water spray will be used (drilling from the outside), and (2) the workman, stationed at the breakout area on the inside wall, in addition to monitoring when the positive feed drill penetrates the walls, will hold a small enclosure against the wall to collect and contain any generated dust, dirt, debris and water when the break-through occurs.
In addition to the previously described me6sures taken to contain and collect any dust or debris that may be released in the room, the licensee has committed to employ alternate equip-ment to reduce dust level in the unlikely event that the dust l
level should become excessive (that is, reach a level at which it could potentially affect equipment performance).
Filtered venti-lating air is supplied to this room through an air intake located on the Control Building roof at elevation 116', far above the level at which dust and dirt will be generated from construction work.
Routine surveillance will be made to verify that no dust enters the room around the-door seals as a result of other con-struction activities being carried on outside the room.
Q.106 What is your conclusion regarding the effect of the modification work on the operation.of the equipment within the Control Building Electrical Auxiliary Room?
A.106 Based on our review of the subinittals and compliance with the requiremen_ts noted by us above, we conclude that adequate measures
. will be employed to preclude dust, dirt and debris levels which could adversely affect the operation of the equipment within the Control Building Electrical Auxiliary Room.
A.107 Will the equipment in the Engineered Safety Feature Switchgear Room be affected by the dust and dirt generated during the build-ing modifications?
A.108 No.
Q.108 What is the basis of your opinion?
A.108 The Engineered Safety Feature Room, located in the Turbine Build-ing at elevation 69 feet, has no outside air intake system.
4 Ventilation and cooling are provided by a recirculation system.
The room is closed and locked. During the modifications, periodic routine surveillance of the room will be performed to verify that no dust or dirt has entered around the door seals. No modifi-cations will be made to the room's existing floor, walls, ceiling or penetrations and, as such, the modification work will not generate dust or dirt within the room itself.
Based on the measures to be taken to control the generation and accumulation of dust at the respective work areas and the periodic l
e.
. surveillance for the entry of dust into the Engineered Safety Feature Room, we believe that equipment within the Engineered Safety Feature Room will be adequately protected from dust and dirt generated during the building modifications.
Q.109 Identify the reasons for your concern that the dust and dirt from the proposed modifications may adversely affect equipment in the Control Room.
A.109 The Control Building modifications will require the drilling of a number of holes in the walls of the Control Room.
On the west wall, the holes are for anchoring the three-inch thick plates to the building's outer surface and on the east wall for bonding of the added reinforced concrete wall. The drilling of the holes has raised concerns about the possible entry and adverse effects of construction-generated dust and dirt on the operation of the equipment in the Control Room. The concern in this regard is that dust could settle on electrical contact points thereby impairing adequate electrical contact.
Q.110 What measures will be taken to assure that the adequacy of elec-trical contact in the Control' Room is not impaired by construction-generated dirt and dust?
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. A.110 The drilling operations will be conducted from the outside wall surface with drilling equipment using a positive feed control, diamond tipped core drills and wet drilling techniques.
The wet drilling technique will significantly reduce the generation of
' dust.
In addition, the workman stationed at the inside wall, to visually observe and alert the driller when the wall has been penetrated, will also hold a small enclosure over the area to collect and contain any resulting dust, dirt,' debris and water when breakthough occurs.
Further, regular periodic cleanups will limit the accumulation of dust and dirt.
The licensee has indi-cated that if, in spite of the above measures, excessive levels of dust or dirt result from the drilling operations, the licensee wili ~
use lighter equipment.
In addition, all Control Room electrical equipment housing electrical contacts are located in fully enclosed cabinets.
The Control Room nay~ be required, under certain condi-tions, to be maintained at a slight positive pressure relative to the outside.
In order to maintain the capability of developing and maintaining a slight positive pressure differential in the Control Room, should it be required, each hole will be temporarily plugged after being drilled.
Further, during installation of the through bolts to support the steel plates, the sequence of steps will be such that not more than one hole will be open to the atmosphere at one time.
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Q.111 Do you believe that these measures will limit the amount of dust entering the Control Room so that it will have no adverse effect on the operability of equipment and instrumentation?
A.111 Yes.
Q.112 Based upon the above testimony, what is your conclusion with regard to CFSP Contentions 12 and 13?
A.112 We believe that, with the precautions and conditions outlined above, the Trojan facility can be operated safely while the modification work is being performed and that it has been demon-strated that operation during the modification work will not pose an undue risk to the public health and safety.
Q.113 Based upon the above testimony, what is your conclusion with regard to CFSP Contention 15?
'A.113 We believe that-all safety equipment and equipment important to the safe operation of the Trojan facility which could be affected by the proposed modification work has been identified.
A.114.
Based upon the above' testimony, what is your conclusion with regard to CFSP Contention 16?
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A.114
-We believe that adequate measures and procedures will be taken to assure that all safety equipment and equipment for safe operation during.the modification work will not be damaged or adversely affected by the modification work.
Q.115 Based upon the above testimony, what is your conclusion with regard to CFSP Contention 17?
A.115 We believe that performance of the modification work will not hamper the ability of' plant operators to properly respond to an emergency and accordingly will not pose an undue risk to the public health and safety.
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3 Fred Clemenson PROFESSIONAL QUALIFICATIONS PLANT SYSTEKS BRANCH DIVII ON OF OPERATING REACTORS I am employed as a Principal Engineering Systens Analyst in the Pitnt Systems Branc!.. Division of Operating Reactors U.S. Nuclear.
Regulatory Commission, Washington...D.C.
My duties consist of revicding and evaluating the associated safety considerations on nuclear plcnt systens and associated engineering fields on power, test and research reactors.
In this capacity I am also responsible for coordinating the e.ctivities of other assigned branch m2mbers.
I am responsible for providing technical input to various documents including Safety Evalcations, technical positions for Commission criteria as well as industry standards which have been assigned to the Branch.
After having served three years in the Navy (1942-1945) as an electronics technician, I attended University of Washington, Seattle, 1:ashington and received a B.S. degree in Mechnical Engineering in 1948.
Uhereupon I was employed as a instructor by the Pkchanical Engineering D2partment of Oregon State College, Corvallis, Oregon, 1949-1950 v:here I taught courses in Statics, Dynanics, Elenents of Vachanisms, Strength of ihterials and Machine Design.
In September of 1950 I joined the Caneral Electric Company's Reactor Design Division in Richland, Washington as a design engineer.
From that time to the present, my professional experience has been in the field of nuclear engineering.
r I have been a licensed professional engineer in nuclear engineering from the State of California since March 1977, certificate nuder 1166.
At the (kneral Electric Cocpany I designed an automatic shutdo.m r.cchanism and a remotely operated handling system for radioactive caterials.
From November 1951 to May 1956 I was employed by /c.ericcn Machine and Foundry Co.. (AMF) New York, New York.
There I assisted in activities related to the design and development of a wide variety of specialized mechanical equipment for the production reactors at Savannah River Project, and AMF's line of swiming pool type research rea c tors.
Daring this time I served as a development and testing engineer for the prototype and production models of the control and shutdown mechanisms for the Savann'ah River production reactors.
Fo11 wing this I served as the senior company representative, field engineer and consultant to E.I. DuPont de Nemours and Company during the installation, checkout'and acceptance tests of the control, shutdun and refueling equipment designed by A erican Machine and Foundry Company on all five production reactors. Following this.
I directed the design, development, assembly and testing of a versatile rcuarch reactor control rod drive mechanism and other accessories.
From May 1956 to June 1958 I was employed by Combustion Engineering Inc., Windsor, Conn. as a Nuclear Engineer III. During this time. I served as <the mechanical core design group leader where I directed the design of refueling equipment, fuel elements and supporting structurt j.
for a submarine reactor. Patent applications were applied for on two e
m2thods.I developed to support the fuel elements.
From July 1958 to June 1961. I was employed as a Staff Enginter by G2neral Nuclear Engineering Corporation Duneden. Florida.
I was responsible for the conceptual and detailed design of two prototype. -
control rod drive m?chanisms for a low enriched, gas-cooled nuclear power reactor, as well as a test stand to test a high temperature, high pressure gas manifold assembly. A patent application was submitted on the method I developed to decelerate a control rod.
From September 1961 to October 1963. I klas employed by the Ato;.iics Division Nuclear Space Group of Aerican Machine and Foundry Co:9tny, Greenwich, Conn., where I developed a remote handling system used in the
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ri.aintenance and disassembly of the radioactive Nerva engine as well as l
assisting in other nuclear space proposals.
From October 1963 to April 1966. I was employed as a Senior Engineering Specialist by the Nuclear Division of Martin Marietta Company Inc.
During this time I was responsible for the design and development of remotely, operated handling equipment required in processing highly radioactive heat sources, the manufacturing tooling required in the manufacture of thermo-electric devices, and the i
ranufacturing tooling utilized for the fabrication of the fuel elements i
and control rods for the Mi-IA, a floating nuclear. power plant. built by l-
~ the Dapartrant of the Army.
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Froe Phy 1966 to the present. I have been employed by the U.S.
Atomic Energy Commission and U.S. Nuclear Regulatory Commission.
Daring the first two years I was in the Division of Reactor Standards where I worked on the development of standards and assisted the Division of Reactor of Licensing on a number of projects.
For the next three years I was a project leader in one of the boiling water reactor project branches in the Division of Reactor Licensing.
In addition to working on a number of special technical assignments I participated in the review of the Southwest Experimental Fast Oxide Reactor (SEFOR) and the Enrico Fermi Atomic Poder Plant Unit 2, a boiling water reactor.
From April 1972 to December 1975 I was assigned as a Senior Systems Engineer to the Auxiliary and Power Conversion Systers Branch of Division of Technical Review. I was responsible for the review of the design, development and operation of auxiliary and power conversion tystems of BWRs, PWRs and HTGRs.
I developed generic positions on specific NRC concerns such as Ultimate Heat Sinks Fuel Cask Handling. Tornado Missiles, Turbine Missiles and Fire Extinguishants.
I developed Standard Review Plans and participated in the development of industry standards on Safety Related Yalves and Emergency Onsite Diesel G2nerator Fuel Oils Storage and Supply Systems.
l From Dacember 1975 to the present I've been a member of the Plant Systers Branch, Division of Operating Reactors. My duties in this branch consist of safety reviews and evaluation of systems design and e
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. operation of nuclear pwer, test and research reactors.
As re:;uired. I prepare safety evaluations and take presentations to the Advisory Ccm.ittee on Reactor Safeguards. I have participated in the developmnt of industry standards, Regulatory Guides, and NURIG documents rela to safety relief valves, eargency onsite diesel generators, heavy load handling equipmnt and reactivity control system requirements and n.odifications.
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James E. Knight Division of Operating Reactors U. S. Nuclear Regulatory Commission Pr_ofessional Qualifications I am a Senior Electrical Engineer in the Systematic Evaluation Program Branch, Division of Operating Reactors, Office of Nuclear Reactor Regulation, U.'S.
Nuclear Regulatory Comission.
I am responsible for all aspects of Instrumentation, Control and Power Systems reviews associated with safety rev'fews of the operating power reactors assigned to the Systematic Evaluation Program Branch.
I received a Bachelor of Science degree in Electrical Engineering from Lawrence Institute of Technology in 1967.. Additional graduate studies were subsequently performed at Wayne State University.
Other educational background includes:
1.
Air Force electronics school, one year; 2.
Nuclear Engineering course covering Boiling and Pressurized Water Reactors -
sponsored by Detroit Edison (6 months) 1974; 3.
Fire Protection for Nuclear Power Plants - NRC sponsored (2 weeks) 1974; 4.
Boiling Water Reactor Simulator school - NRC sponsored (2 weeks) 1978; 5.
Pressurized Water Reactor Simulator school - NRC sponsored (2 weeks) 1979.
I am a registered professional engineer of the State of Michigan having been qualified by written examination.
I have been certified since October 1, 1970.
From 1960 to 1967 I was employed by Atomic Power Development Associates Incorporated as a test facility supervisor responsible for design, installa-tion, maintenance and calibration of instrumentation, control and electrical equipnent for special process loops and test rigs (involving nuclear technology)
-related to the Fermi I fast breeder reactor.
From 1967 to 1973 I was employed as a senior electrical engineer for Atomic Power Development Associates Incorporated responsible for electrical, instru-mentation, and control designs and modifications to the Enrico Fermi I power plant, the development of electrical testing and analysis of the Fermi I emergency power systems, and the development of specialized tools and instrumentation for liquid metal cooled reactors.
From 1973 to 1975 I was employed by the Detroit Edison Company as a senior electrical engineer,-acting as system engineer _in the project management office of the Enrico Fermi II Boiling Water Reactor. As a system engineer I was responsible for management of the design of-instrumentation and control systems for safety systems and balance-of-plant systems from concept to final design. _ Responsibilities included design review and approval, resolu-tion of safety and technical problems, and the development of the safety analysis report on instrumentation and control.
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r.om 1975 to present I have been employed by the Nuclear Regulatory Commission ts a Reactor Engineer (Instrumentation); 1975-1976 in the Division of Technical Review, from 1976 to September 2, 1979 as an Engineering Systems Analyst and Senior Engineering Systems Analyst in the Division of Operating Reactors and from September 2, 1979 to present as a Senior Electrical Engineer in the Systematic Evaluation Program Branch.
In these capacities, I have been responsible for numerous safety reviews on boiling and pressurized water reactors including the fire protection reviews of fifteen operating react, ors.
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